Summary
- Businesses in Poland face a growing tax compliance burden
- Proposed corporate income tax changes in Poland for 2027
- How could tax incentives change in Poland?
- Temporary sectoral CIT increase in Poland
- KSeF in Poland: mandatory e-invoicing is now in force
- Pillar Two obligations in Poland: what should businesses focus on?
- Public CbCR reporting in Poland
- JPK_CIT implementation in Poland
- Mandatory disclosure rules in Poland
- Other tax developments under review in Poland
Businesses in Poland face a growing tax compliance burden
Poland continues to introduce major tax compliance obligations while simultaneously reviewing a range of significant tax policy changes. For multinational groups operating in Poland, 2026 is a year of implementation, adaptation and preparation for new reporting requirements. At the same time, businesses should closely monitor legislative proposals that could substantially affect their effective tax burden in Poland from 2027 onwards.
From mandatory e-invoicing and Pillar Two compliance to JPK_CIT reporting and public country-by-country reporting, companies with operations in Poland should ensure that their systems, governance processes and tax functions are fully prepared. Looking ahead, proposed changes to corporate income tax rates and tax incentives could have a significant impact on investment decisions and business planning in Poland.
Proposed corporate income tax changes in Poland for 2027
One of the most important tax proposals under consideration in Poland is an increase in the standard corporate income tax rate from 19% to 22% for the largest taxpayers and tax capital groups from 2027.
The proposal would apply to:
- Tax Capital Groups
- taxpayers with annual revenues exceeding EUR 50 million
- taxpayers subject to Pillar Two obligations in Poland
Importantly, certain Polish entities belonging to Pillar Two groups could be affected even if their own revenue does not exceed the EUR 50 million threshold. Multinational groups should therefore evaluate the potential impact of the proposed Polish CIT increase on future operations and tax costs.
Important
Certain Polish entities belonging to Pillar Two groups could be affected even if their own revenue does not exceed the EUR 50 million threshold. Multinational groups should therefore evaluate the potential impact of the proposed Polish CIT increase on future operations and tax costs.
How could tax incentives change in Poland?
The Polish Ministry of Finance is currently reviewing several tax incentives. Among the key proposals are a 10-year extension of the robotisation tax relief until 2036 and the abolition of the expansion relief.
Businesses investing in Poland should reassess investment plans, automation projects and growth strategies that rely on incentives currently under review. Early analysis may help organisations better understand potential changes to expected returns and tax benefits.
Temporary sectoral CIT increase in Poland
Poland is also considering a temporary increase of the CIT rate to 30% for selected large entities operating in the fuel, oil and gas, and energy sectors from 2027. The rate would subsequently be reduced over time.
Important
The proposal is expected to apply to taxpayers with annual revenues above EUR 50 million and Tax Capital Groups. If implemented, it could significantly affect tax costs, financing strategies and investment planning for affected businesses in Poland.
KSeF in Poland: mandatory e-invoicing is now in force
The national e-invoicing system (KSeF) is now fully operational in Poland. Mandatory e-invoicing has applied to the largest taxpayers since 1 February 2026 and to all remaining taxpayers since 1 April 2026, subject to transitional measures introduced during the implementation period.
KSeF requires businesses in Poland to exchange invoices through the platform operated by the Polish tax authorities. For many organisations, this has required substantial adjustments to ERP systems, accounts payable and receivable processes, invoicing workflows and shared service centre operations.
Multinational groups with Polish subsidiaries should assess whether Poland’s KSeF requirements create a need for broader changes at group level, including governance frameworks, process ownership and technology architecture.
Pillar Two obligations in Poland: what should businesses focus on?
For many international groups, 2026 represents the first practical year of implementing Pillar Two compliance obligations in Poland. Depending on their circumstances, Polish entities may need to submit GIR notifications, verify the applicability of safe harbours and prepare QDMTT filings.
Groups operating in Poland should verify that data collection processes, reporting frameworks, governance structures and documentation requirements are fully operational. Particular attention should be paid to the allocation of responsibilities between headquarters and Polish entities to ensure compliance with evolving Polish Pillar Two regulations.
As further legislative developments remain under discussion in Poland, businesses should continue monitoring changes and assessing their potential impact.
Public CbCR reporting in Poland
The first practical public country-by-country reporting (Public CbCR) cycle for many groups will relate to the 2025 financial year and be published during 2026. Public disclosures are accessible to a wide audience, including tax authorities, investors, employees, NGOs and media organisations.
For certain non-EEA groups operating in Poland, reporting obligations may arise at the level of a Polish subsidiary or branch if the parent company does not publish the required report. Companies with Polish operations should therefore determine whether a reporting obligation exists in Poland and clarify responsibilities for publication and stakeholder management.
JPK_CIT implementation in Poland
Poland has started the phased implementation of SAF-T reporting for corporate income tax purposes through JPK_CIT requirements. These obligations include JPK_KR_PD for general ledger and tax-related adjustments, as well as JPK_KR_ST for fixed assets and depreciation records.
Businesses in Poland are required to provide detailed accounting and tax information in a structured electronic format within prescribed reporting deadlines. Successful implementation often requires reviews of chart-of-accounts mapping, tax adjustment processes, ERP configurations and data extraction capabilities.
Important
Fixed asset registers, depreciation records and overall data quality remain among the most challenging areas for many taxpayers in Poland and should be assessed well in advance of reporting obligations.
Mandatory Disclosure Rules in Poland
The Polish Mandatory Disclosure Rules (MDR) framework is scheduled to be significantly simplified from 1 October 2026. The most notable change is the planned removal of domestic arrangement reporting requirements, while maintaining the obligation to report cross-border arrangements under DAC6.
Although the scope of MDR reporting in Poland may narrow, companies should continue reviewing cross-border transactions and arrangements to ensure ongoing compliance.
Other tax developments under review in Poland
Additional tax changes are being considered in Poland, including potential amendments relating to personal income tax and family foundations. Businesses and investors should continue monitoring legislative developments as proposals progress through the legislative process.
Poland remains one of the most dynamic tax environments in Europe, with significant compliance obligations already in force and important tax changes under consideration for 2027. Companies operating in Poland should ensure that compliance frameworks are fully implemented while also assessing how proposed CIT changes, tax incentives and sector-specific measures may affect future business decisions.
